Concerns about HCA Identification Methods Prompts Advisory

Citing concerns that intrastate and small gas transmission pipeline operators may not be accurately identifying high consequence areas (HCAs) as part of their integrity management programs (IMP), PHMSA issued yet another advisory to the industry on December 12, 2016. In its seventh advisory issued this year, PHMSA explains the need for further guidance on the methodology based on recent inspections as well as a Safety Recommendation issued by the National Transportation Safety Board (NTSB) in 2015 (NTSB Recommendation P-15-06, issued in conjunction with the Board’s Safety Study of implementation of gas transmission integrity management rules).

Under the IMP regulations, operators are required to use one of two different methods to identify HCAs, and both methods require that an operator both determine “identified sites” and calculate a “potential impact radius” (PIR) in order to assess where a potential pipeline failure could have a significant impact on the public or the environment. 49 C.F.R. Part 192.903. According to the advisory, PHMSA has completed a review of both interstate and intrastate pipeline data, and concluded that many operators do not have procedures to adequately describe how to identify HCAs and that intrastate and small operators have been using inconsistent methods to identify HCAs. This is consistent with the NTSB’s basis for issuing its Safety Recommendation noting that the rate of incidents was 27% higher for intrastate pipelines as compared to interstate pipelines.

The advisory reminds operators of existing guidance and provides further recommendations, including:

the need to improve the accuracy of pipeline data and mapping systems (and the expectation that large operators will use geographic information system or similar mapping software for segment identification);

the importance of frequent monitoring of surrounding conditions along a pipeline (including updates to “identified sites” for operators using Method 2);

the need to report and review that information;

the need to have accurate MAOP data to calculate a PIR; and,

the need to include an appropriate tolerances or buffer zones to the calculated PIR to ensure proper HCA identification.

PHMSA also recommends that operators frequently (at least annually) and consistently review both class location and PIR data as part of a robust IMP.

Meanwhile, operators still await the issuance of PHMSA’s expansive gas pipeline safety rulemaking that was proposed earlier this year, with over 600 comments submitted in July 2016. If finalized as proposed, the rulemaking will be the largest in the history of PHMSA, nearly doubling the size of the Part 192 regulations.